CRA guidance draft draws meaty comments

The comment period closed yesterday on a "question and answer" interpretive document proposed by three major banking agencies as guidance on their Aug. 2 rule for Community Reinvestment Act enforcement. The FDIC has already posted copies of the comments, including quite a few (can't tell if all) of yesterday's last-minute letters. As usual there's some boilerplate and repetition, but some of these comments are definitely worth a read. Knowledgable industry groups such as the National Association of Affordable Housing Lenders, the Independent Community Bankers of America, and the National Community Reinvestment Coalition (also here... and here... and here) do a helpful job of explaining the Q&A material in their critiques. These groups disagree pretty fundamentally on money questions, so together their comments provide an interesting preview of coming interpretation battles on the new CRA rules -- especially regarding incentives for disaster relief and the new intermediate examination category for banks between $250 million and $1 billion in assets.

The comment period is still open until April 4 on the separate EGRPRA request for comments on "Prompt Corrective Action" and "Disclosure and Reporting of CRA-Related Agreements." (See our previous note.)

Also at the FDIC today, the agency posted its first state and regional profiles showing the effects of the 2005 hurricanes on local economies and on banking.